TOPAZ JEWELRY GROUP OF COMPANIES’ CODE OF CONDUCT

Our commitment: This Code of Conduct represents our steadfast commitment to ethical and responsible practices in all aspects of our business operations. We conduct our business with respect for human rights and for the environment. We require that all our business partners, companies and persons which we are doing business with follow the same standards.

Our business partners: All of our business partners will adhere to the same commitments as we do and apply the standards stated in our Code of Conduct (in addition to complying with laws, regulations and practices applicable in their country). These requirements and those further stated in our Code of Conduct bind our partners and constitute a condition of conducting business with Topaz Jewelry. It is the responsibility of our business partners to communicate and explain these standards to their employees and to ensure that all subcontractors involved in the production and distribution of our products approve our Code of Conduct in writing and comply with the principles stated therein. In order to ensure that they comply with our Code of Conduct, our business partners must authorize us and our designated agents to inspect their premises. Any partner who is found to not to adhere and implement our Code of Conduct will be in breach of their commitments. We may therefore, at our sole discretion and without any compensation, immediately cancel any existing orders and terminate all existing agreements with such a partner.


Topaz Jewelry USA Code of Conduct Standards:

Standard 1: Compliance with Laws and Regulations We vow to comply to all applicable laws and regulations, inclusive to local and national codes, rules and regulations, applicable treaties and industry standards.

Standard 2: Child Labor We are committed to preventing the unlawful employment of children. We adhere to the United Nations’ and the International Labor Organization's Conventions and Recommendations. We recognize in particular the right of children to be protected from economic exploitation and from partaking in work that is likely to be hazardous or interfere with their education, or harmful to their health or physical, mental, spiritual, moral or social development. We will only employ young persons (below the age of 18 and older than 15 years) in specific circumstances (such as internship or vocational training) and in accordance with the International Labor Organization Convention on Minimum Age of 1973 (ILO Convention No. 138). We are committed to verifying the age of potential employees prior to recruitment and, where young persons are employed, we ensure that they do not work overtime and receive fair payment for completed work, at least twelve hours of nightly rest time, and a minimum of two weekly rest days.

Standard 3: Involuntary Labor We do not allow the use of forced or involuntary labor. All employees are treated respectfully. Physical punishment, violent threats, or other forms of sexual, psychological or verbal harassment are not prohibited.

Standard 4: Safety and Health We commit ourselves to maintaining a safe workplace environment that adheres to all applicable laws and industry standards. We are committed to providing our employees with the best possible human health and safety working conditions. Our employees receive training on health and safety requirements to follow and we maintain adequate procedures. Any incident that we deem severe by conventional standards, will be formally investigated and documented.

Standard 5: Gender and Racial Equality We respect and promote gender and racial equality. We believe in the equality of all genders, races, creeds, and religions.We firmly believe in respecting particularly the rights of men and women of all races for equal pay and work, equal employment opportunities, equal working conditions and equal opportunity for advancement. We are committed to protecting our employees from any kind of discrimination in our hiring and employment practices.

Standard 6: Environmental Compliance We are committed to complying with all applicable environmental laws and regulations and to introducing management and operating systems that minimize our impact on the environment. We are committed to disposing of waste substances in compliance with applicable laws and to taking steps to reduce the quantity of waste/emissions produced and energy/natural resources used. Additionally, we ensure the efficiency of our business operations in terms of consumption of natural resources, including, but not limited to, water and energy. We do not manufacture, trade and/or use chemicals and hazardous substances, unless where techniques do not permit to do otherwise (in which circumstances legal requirements will be complied with).

Standard 7: Money Laundering and the Finance of Terrorism We are committed to acting against money laundering and the finance of terrorism, maintaining an anti-money laundering policy, auditing financial accounts and acknowledging the identity of all persons and organizations we deal with. We acknowledge that any transaction that is of international scope may be subject to more than one regulation.

Standard 8: Diamonds and Stones We adhere to a voluntary program of self-regulation in the diamond and gemstone trade industry. We do not knowingly buy or sell conflict diamonds, according to the Kimberley Process1. We adhere to and will keep records of audited and reconciled Kimberley Process Certificates. We adhere to the World Diamond Council Resolution on Industry Self-Regulation, keep records of all invoices (which shall contain the World Diamond Council warranty statement2) and have a system to prevent the purchase or sale of illegal diamonds. Employees are informed of the restrictions on the buying or selling of diamonds. 1 The Kimberley Process is a joint government, international diamond industry and civil society initiative to stem the flow of conflict diamonds. For the Kimberley Process purpose, “conflict diamond” refers to a rough diamond used by rebel movements to finance wars against legitimate governments. 2 ‘The diamonds herein invoiced have been purchased from legitimate sources not involved in the funding of conflict and in conformance with United Nations resolutions. The seller hereby guarantees that these diamonds are conflict free, based on personal knowledge and/or written guarantees provided by the supplier of these diamonds’.

Standard 9: Conflict Minerals We are committed to acting against Conflict Minerals sourcing and assure that our Gold material providing from our business partners does not directly or indirectly finances or benefits armed groups causing serious human rights abuses. Our business partners must, to the best reasonable extent, ensure ethical sourcing, complete their due diligence on the source and chain of the custody of Gold, and make this due diligence available upon request.

Standard 10: Product Security We maintain product security procedures within the premises and during shipments. Armed security personnel will not be used, unless it is strictly necessary to do so. We always prioritize the security of employees, visitors and other relevant business partners.

Standard 11: Product Integrity We comply with all relevant and applicable trading standard legislation. We disclose all product physical characteristics accurately and do not make any untruthful statements, representations or material omissions. We disclose the fineness of the gold we use, apply authorized gold quality marks and properly disclose the description of diamonds and the quality of precious and semi- precious stones, which includes the proper disclosure of treated diamonds, laboratory created diamonds and simulants.

* As defined in 2010 United States legislation, Dodd-Frank Wall Street Reform and Consumer Protection Act, Section 1502(e)(4): CONFLICT MINERAL - The term ‘‘conflict mineral’’ means: 1 - columbite-tantalite (coltan), cassiterite, gold, wolframite, or their derivatives Or: 2 - any other mineral or its derivatives determined by the Secretary of State to be financing conflict in the Democratic Republic of the Congo or an adjoining country. (Available at http://www.sec.gov/about/laws/wallstreetreform-cpa.pdf)

We will continue to update our Code of Conduct and all of our business partners must accept these updates unless such amendments have a substantial effect on them.